4. Anti bribery procedures
In relation to section 7 of the Act, an organisation will have a defence to this corporate offence if it can show that it had in place adequate procedures designed to prevent bribery by or of people associated with the organisation.
Our procedures are based on six principles:
We have procedures in place to prevent bribery by people associated with it. These are proportionate to the bribery risks faced by the Council and to the nature, scale and complexity of the Council’s activities. They are also clear, practical, accessible, effectively implemented and enforced.
Top level commitment
The Chief Executive and his Management Team are committed to preventing bribery by people associated with it. They foster a culture within the organisation in which bribery is never acceptable.
The nature and extent of the Council’s exposure to potential external and internal risks of bribery on its behalf by people associated with it is periodically assessed. This includes financial risks but also other risks such as reputational damage.
We take a proportionate and risk based approach, in respect of people who perform or will perform services for or on behalf of the organisation, in order to mitigate identified bribery risks.
Communication (including training)
We seek to make sure that its bribery prevention policies and procedures are embedded and understood throughout the organisation through internal and external communication, including training that is proportionate to the risks it faces.
Monitoring and review
Procedures designed to prevent bribery are monitored and reviewed and improvements are made where necessary.